The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 14 Nov 2024 (UK):
The UK Government passed the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2.) Regulations 2024 (the "Amendment Regulations"), which makes key amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (the "UK Russia Regulations"). Most of the amendments will come into force on December 5, 2024; the extension of financial sanctions reporting obligations to new sectors will come into force on May 14, 2025.
- 14 Nov 2024 (UK):
The Office of Financial Sanctions Implementation ("OFSI") published new UK Financial Sanctions FAQs (the "FAQs") (FAQs 125-131) to reflect the new required payments exception, introduced by the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 (the "Amendment Regulations"). The required payments exception will come into force on December 5, 2024.
- 13 Nov 2024 (BIS):
The U.S. Department of Justice ("DOJ") announced that Stanislav Romanyuk, a Ukrainian national last residing in Estonia, was sentenced to 33 months in prison, followed by three years of supervised release, after pleading guilty to charges of violating U.S. export control laws and international money laundering conspiracy. The charges stem from Romanyuk's attempt to smuggle an export-controlled jig grinder from the United States to Russia via Latvia. Romanyuk was arrested in June 2022 and pleaded guilty in May 2024. Two Latvian co-conspirators have pleaded guilty to similar charges.
- 12 Nov 2024 (Ukraine):
Content provided in collaboration with Sayenko Kharenko.
Under the Decree of the President of Ukraine “On the Decision of the National Security and Defence Council of Ukraine of 12 November 2024 “On Application of Personal Special Economic Sanctions and Other Restrictive Measures (Sanctions)" No. 762/2024, dated 12 November 2024, different sanctions were applied to 63 enterprises related to Russia's invasion to Ukraine (mainly in the field of aviation).
- 12 Nov 2024 (Ukraine):
Content provided in collaboration with Sayenko Kharenko.
Under the Decree of the President of Ukraine “On the Decision of the National Security and Defence Council of Ukraine of 12 November 2024 “On Application of Personal Special Economic Sanctions and Other Restrictive Measures (Sanctions)" No. 761/2024, dated 12 November 2024, different sanctions were applied to 15 individuals and 32 enterprises related to Russia's invasion to Ukraine.
- 07 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2024/5394840 (the "GL") in respect of Payments made in the year 2022 between non-designated third parties involving Designated Credit or Financial Institutions.
- 07 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") designated 16 individuals and 31 entities under the Russia (Sanctions) (EU Exit) Regulations 2019.
- 07 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Sanctions Implementation ("OFSI") issued a two-week extension for the submission of reports under the annual Frozen Asset Review. The new deadline for reports to be submitted to OFSI is November 25, 2024. OFSI also updated its UK Financial Sanctions FAQs ("FAQs") to explain the new deadline.
- 05 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") updated several of its UK Financial Sanctions FAQs ("FAQs") regarding the new Legal Services General Licence INT 2024/5334756 (the "General Licence").
- 05 Nov 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Union ("EU") issued updated FAQs regarding restrictive measures in relation to intellectual property rights ("IPRs"). The FAQs clarify key aspects of Article 5s of Council Regulation (EU) 833/2014 ("Regulation 833/2014"), introduced as part of the EU's 14th package of sanctions against Russia on June 24, 2024.
- 04 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
His Majesty's Revenue and Customs ("HMRC") confirmed that a compound settlement offer was issued to a UK exporter in August 2024 for breaching The Russia (Sanctions) (EU Exit) Regulations 2019 ("Russia Regulations").
- 01 Nov 2024 (BIS):
The Akin Summary document has now been posted for this action.
The Bureau of Industry and Security ("BIS") added 44 entities under 46 entries to the Entity List under the destinations of China (11), India (5), Malaysia (2), Russia (13), Singapore (1), and Turkey (14). According to BIS, these entities were designated for shipping or attempting to ship U.S.-origin and U.S.-branded items to Russia in violation of U.S. export controls; for engaging in research, production, or attempted procurement of materials in support of Russia's chemical and biological warfare program; or for engaging in other activities contrary to U.S. national security and foreign policy interests. Included among these 44 entities are four address-only entries: Address 12, Address 13, Address 14, and Address 15, all under the designation of China. BIS also modified 49 entries under 52 existing entries on the Entity List to add a footnote 3 designation; these entities were listed under the destinations of China (42), India (4), Turkey (2), the U.K. (2), Estonia (1), Finland (1) and the UAE (1).
- 01 Nov 2024 (BIS):
The Akin Summary document has now been posted for this action.
The Bureau of Industry and Security ("BIS") issued a new final rule (effective November 1, 2024) that amends the Export Administration Regulations ("EAR") to strengthen existing export control restrictions against Russia and Belarus. The final rule (i) expands the scope of the existing Russian and Belarusian Industry Sector Sanctions to include nine key precursors for riot control agents and chemical weapons; (ii) adjusts certain exclusions, exceptions, and the licensing policy for the official business of diplomatic or consular missions of governments of Country Group A:5 and A:6 destinations that are located in Russia or Belarus; and (iii) clarifies the applicability of license requirements for the Entity List Foreign Direct Product ("FDP") rules.
- 30 Oct 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") and the U.S. Department of State designated 32 individuals and 365 entities, pursuant to Executive Order ("EO") 14024. The designations target Russia's military-industrial base and sanctions evasion networks, including persons and entities from Russia as well as Belize, Benin, Bulgaria, the British Virgin Islands, Chile, China, Cyprus, Germany, India, Kazakhstan, Kyrgyzstan, Malaysia, Montenegro, Serbia, Singapore, Switzerland, Thailand, Türkiye, the United Arab Emirates, and Uzbekistan.
In addition to the above designations, the U.S. Department of State designated over 120 individuals and entities, pursuant to E.O. 14024. The designations target sanctions evasion networks, Russia's military-industrial base, subsidiaries of State Atomic Energy Corporation Rosatom, and persons in third countries, including China, India, Malaysia, Thailand, Turkiye, and the United Arab Emirates. The State Department also designated several senior Russian Ministry of Defense officials.
Concurrent with these designations, OFAC issued Russia-related General Licenses ("GLs") 110, 111, and 112 authorizing, subject to certain conditions, certain activities involving certain entities blocked on October 30, 2024. Additionally, OFAC issued amended GL 25G, which adds certain entities blocked on October 30, 2024 with which certain transactions related to telecommunications and internet-based communications are not authorized under the GL. OFAC also issued amended GL 8K, which extends the authorization of certain transactions related to energy that involve one or more blocked persons that are specifically listed in the GL until 12:01 a.m. Eastern Daylight Time on April 30, 2025.
Lastly, OFAC issued one new FAQ (1198) and amended two existing FAQs (976 and 1040).
- 30 Oct 2024 (Switzerland):
The Akin Summary document has now been posted for this action.
The Swiss Federal Council adopted further sanctions against Belarus in line with the measures adopted by the EU on 29 June 2024.
- 29 Oct 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2022/2300292 (the "GL") in respect of Permitted Payments to Energy Companies for gas and electricity supplies.
- 28 Oct 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") designated three individuals and three entities under the UK's Russia sanctions regime, pursuant to The Russia (Sanctions) (EU Exit) Regulations 2019.
- 09 Oct 2024 (BIS):
The Akin Summary document has now been posted for this action.
BIS published guidance to financial institutions ("FIs") recommending best practices regarding due diligence, ongoing reviews of transactions to identify potential red flags, and real-time screening for FIs to comply with the Export Administration Regulations ("EAR"), including General Prohibition 10 ("GP10").
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